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Review Applicability of Tier II Reporting Requirements

The Emergency Planning and Community Right to Know Act (EPCRA) is authorized by Title III of the Superfund Amendments and Reauthorization Act (SARA). In an effort to keep communities aware of the hazardous chemicals present at facilities exceeding certain thresholds, Section 311 and 312 of EPCRA stipulate requirements for the reporting of hazardous chemical storage. These reporting requirements allow State and Local emergency response and planning committees to be aware of the hazardous materials present within their jurisdiction.

Facilities that possess more than 500 pounds of an extremely hazardous substance (EHS), 10,000 pounds of any other hazardous chemical, or greater than the threshold planning quantity (TPQ) for a chemical at any time during the year, are required to file a Tier II report annually.  40 CFR 355 codifies the chemicals that are considered extremely hazardous substances, and the EPA publishes the List of Lists that can be referenced to find TPQs.

If a full EPCRA applicability review of the hazardous chemicals in storage and use at your facility has not been conducted to determine if the chemical inventory approaches any reporting requirements, now would be a good time to conduct this review. The deadline to file Tier II reports for reporting year 2015 is March 1, 2016. Reporting is now completed utilizing an electronic reporting system. So take the time to review your chemical inventory if you have not done so already, and prepare to file if you are required to complete a Tier II report.

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